The Eighth Circuit's analysis of whether a sham exists consists of two prongs: (1) under the business-purpose test, "a transaction will be characterized as a sham if 'it is not motivated by any economic purpose outside of tax considerations'"; and (2) under the economic-substance test, if it "is without economic substance because no real potential for profit exists" (5 IES Indus.

ARCADIA - The way they ran in the Sham Stakes at Santa Anita on Sunday, it was as if Master David knew he needed a victory to earn a ``Derby horse'' badge and Action This Day knew he was a champion just shaking off the winter rust.

Slogan of Shams Radio -- press photo CAIRO -- 16 December 2017: Association Shams -- an organization that campaigns for the decriminalization of homosexuality in Tunisia -- launched the first Arab web-radio station for the LGBT (lesbian, gay, bisexual and transgender) community on Tuesday.

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